IFC’s appraisal considered the environmental and social management planning process and documentation for the Project and gaps, if any, between these and IFC’s requirements. Where necessary, corrective measures, intended to close these gaps within a reasonable period of time, are summarized in the paragraphs that follow and (if applicable) in an agreed Environmental and Social Action Plan (ESAP). Through implementation of these measures, the Project is expected to be designed and operated in accordance with Performance Standards objectives.
PS1: Assessment and Management of Environmental and Social Risks and Impacts
Environmental and Social Management System
Polar’s Corporate Identity Statement includes a commitment to promoting equality, community well-being, and minimizing environmental impact. The Company manages E&S risks in line with state/national law and standards. E&S policies and procedures at the corporate level include an Environmental Policy, Construction Contractor Management Policy (CCMP), Code of Conduct, Code of Ethics, HR Handbook among others, while E&S plans specific to each hospital include, for example, an Internal Civil Protection Program (ICPP) and waste management plans. Specific initiatives to standardize E&S performance across the portfolio are established in Polar’s new hospital “Integration Playbook”. In order to systematically manage E&S at the corporate level, in full alignment with the requirements of the IFC PS, as per ESAP item #1, the Company will build on its existing E&S policies and procedures to develop a corporate E&S Management System (ESMS) per state/national law, the requirements of IFC PS, WBG EHS Guidelines for Health Care Facilities (2007) and WBG General EHS Guidelines (2007). The ESMS will be implemented across the current and future portfolio of hospitals, commensurate to the scale and impacts of its activities.
For prospective hospital acquisitions, the Company screens potential targets, including E&S aspects. An E&S impact assessment for remodeling works is not required per national law, but such assessments may be legally required for hospitals which will be acquired as part of the project, depending on the state they are located in and the remodeling scope. For prospective hospital &/or land acquisitions, as per ESAP item #2, Polar will build on existing processes to develop an E&S Due Diligence Procedure to ensure that E&S risks and impacts are adequately identified. For operating hospitals, as part of ESAP item #1, Polar will develop an E&S Assessment and Management Procedure to systematically identify and mitigate E&S impacts and risks. Both procedures will be in accordance with the requirements of IFC PS, WBG EHS Guidelines for Health Care Facilities (2007) and WBG General EHS Guidelines (2007).
Organizational Capacity and Competency
OHS is the responsibility of the Chief Operations Officer, while environmental projects and contractor management are the responsibility of the Projects Director. Each role reports directly to the Chief Executive Officer. As per ESAP item #3, Polar will recruit a qualified EHS Coordinator/Manager (with knowledge of the national regulatory requirements and applicable requirements of IFC PS), responsible for the development, implementation and maintenance of the ESMS and related E&S programs, plans and procedures.
Emergency Response Planning
In line with state/national law and standards, each hospital has prepared and implemented a documented ICPP, which includes assessment of emergency scenarios, structural safety, emergency response procedures, evacuation plans, communication protocols, training, drills, and coordination with external agencies. The program is approved by the state civil protection authority.
In order to systematically manage emergency preparedness and response (EPR) at the corporate level, as per ESAP item #4, Polar will develop and implement a corporate EPR procedure in accordance with the requirements of IFC PS, WBG EHS Guidelines for Health Care Facilities (2007) and WBG General EHS Guidelines (2007), focusing on patient safety, probable risk scenarios, addressing the methodologies to be used for evacuation and specifying the required training of medical and nursing personnel. The procedure will define the roles and responsibilities to manage EPR across the portfolio. Each hospital will update their ICPP as necessary to align with the corporate procedure.
Monitoring and Review
The Board of Directors are provided with a quarterly report on E&S performance including key metrics, audit results and improvement initiatives. As part of ESAP item #1, the Company will develop procedures to monitor and measure effectiveness of its ESMS and compliance with legal and contractual obligations, including E&S key performance indicators (KPIs) and performance targets.
PS2: Labor and Working Conditions
Polar has approximately 855 direct permanent employees, of which 60% are female. The acquisition of new hospitals is expected to at least double the number of employees in the next two years. 12.5% of Polar’s workforce are contractors, responsible for remodeling, maintenance, as well as cleaners and security guards. Doctors working at Polar’s facilities are self-employed. Employees are free to associate in unions and collective bargaining agreements (CBAs) are in place with two unions, aligned with national law and standards. Interviewed workers confirmed adequate relations with union representatives and CBA implementation.
Human Resources (HR) Policies and Procedures
Each hospital has its own HR department, while the corporate HR Director has overall responsibility for labor matters. Polar’s current hospitals have each adopted their own Internal Work Regulations (IWR), compliant with national law and standards, and aligned with PS2. The relevant IWR, as well as the corporate Code of Conduct and Code of Ethics are distributed and communicated to employees upon hiring and during onboarding. The corporate Code of Conduct includes provisions regarding non-discrimination. In order to systematically manage HR at the corporate level, as per ESAP item #5, Polar will develop and implement a corporate HR policy and related procedures ensuring compliance with IFC PS2 and local labor requirements. Each hospitals’ policies and procedures will be updated as necessary to align with the new corporate requirements, with oversight from the corporate Head of HR. The Code of Conduct will also be strengthened emphasize Polar’s commitment to equal opportunities.
Retrenchment
As part of the acquisition screening process, Polar conducts a workforce assessment and proposes solutions to enhance efficiency. The operational workforce is retained post-acquisition, and any necessary layoffs are carried out in accordance with local regulations. As part of ESAP item # 5, Polar will develop and implement a retrenchment policy aligned with IFC PS2 requirements.
Grievance Mechanism
Polar has a grievance handling procedure to receive grievances from workers, patients, and stakeholders in general, which can be reported anonymously via a website or via email. Workers also have the option to report grievances directly to supervisors or HR. Grievance handling is managed by Polar’s compliance officer via a tracking system. Employees have a good understanding of the grievance mechanism and how to access it. The Code of Ethics includes a zero-tolerance policy SEAH. Grievances related to SEAH are reported through the current grievance mechanisms, allowing for anonymous complaints and confidentiality. These grievances are investigated and managed by an ethics committee composed of trained personnel with representatives from workers and management. Protocols are in place to manage sexually assaulted patients or workers. Personnel are regularly trained on how to manage these types of cases. As per ESAP item #6, Polar will update its grievance handling procedure to include a referral pathway specifically for survivors of SEAH and an annual SEAH training program.
Occupational Health and Safety
Polar manages OHS in line with national law and standards, which includes the formation of a Safety and Hygiene Committee at each hospital, responsible for conducting regular inspections to identify hazards, investigating workplace accidents/illnesses, and proposing preventative measures. Each hospital has an OHS Program which establishes measures and actions to protect workers. Area managers are responsible for ensuring that personnel under their charge are trained on safety measures relevant to their department. Polar has taken steps to prevent hospital-associated infections and risks related to hazardous materials and waste by implementing a range of measures. The Company utilizes engineering and administrative controls, which include advanced ventilation systems, regular environmental cleaning and disinfection, and comprehensive preventive maintenance programs. Hazardous materials and waste are managed in accordance with state/national law and standards, which align with the requirements of the IFC PS. To further enhance prevention, they provide staff, patients, family members, and visitors with appropriate personal protective equipment (PPE).
To systematically manage OHS at the corporate level, as part of ESAP item #1, the corporate ESMS will include an OHS policy and corporate practices in accordance with the requirements of IFC PS, WBG EHS Guidelines for Health Care Facilities (2007) and WBG General EHS Guidelines (2007). Each hospital will develop/revise their OHS policies and procedures as necessary to fully to align with the new corporate requirements.
Workers Engaged by Third Parties
Remodeling projects (ongoing at CMT and planned at HSJ), which primarily consist of upgrades to facades and interiors, are subject to Polar’s CCMP which addresses: (i) contractor selection based on experience, certifications, and cost; (ii) regulatory compliance, OHS safety, and KPIs; (iii) monitoring through inspections and reporting; and (iv) compliance audits and redress mechanisms. Contractors are required to comply with the OHS requirements established in the CCMP and ICPP. During project execution, Polar’s maintenance team conducts weekly inspections of the construction site, and each contractor must report their performance to the Company in a weekly report.
To strengthen its corporate requirements applicable to construction contractors, as per ESAP item #7, Polar will update the CCMP, and create a supplementary procedure, to include: (i) the minimum environmental, OHS, L&FS, labor, community health & safety, SEAH, grievance management, and social requirements in alignment with the IFC PS and the WBG General EHS Guidelines (2007); (ii) the controls to be implemented to verify compliance with the minimum requirements (e.g. inspections, audits, and periodic labor law due diligence); and (iii) actions to record and track the E&S performance, including KPIs.
PS3: Resource Efficiency and Pollution Prevention
Polar has established several resource efficiency and pollution prevention initiatives, such as the goal to reduce carbon emissions by 20% by 2030, and the goal to achieve approx. 50% electricity consumption from solar energy. Following the installation of photo-voltaic panels at CMT, the hospital now generates 90% of its electricity from solar. Other planned initiatives across the portfolio include facade improvements to increase natural ventilation and reduce solar heating, boiler efficiency improvements, recycling initiatives, rain capture projects, and wastewater reuse for irrigation.
Potable water is provided by municipal supply, and wastewater is discharged directly to the municipal sewage system, (subject to wastewater quality testing to demonstrate compliance with the maximum permissible limits established in local law). Hazardous and non-hazardous wastes, including medical wastes and expired medications, are managed in accordance with authorized waste management plans specific to each hospital and disposal is carried out by a licensed third party as per state/national law. These practices are in accordance with the requirements of IFC PS, WBG EHS Guidelines for Health Care Facilities (2007) and WBG General EHS Guidelines (2007).
Remodeling projects will generate wood, metal, plastic, and general waste, as well as waste oil, oil filters, oily rag, used paint, spent PPE. Waste management will be carried out by the construction contractor in accordance with the project’s waste management plan, as per state/national law and standards, which are in accordance with the with the requirements of IFC PS and WBG General EHS Guidelines (2007).
Air emissions are primarily from natural gas-powered boilers and steam generation units, (those in the current portfolio each have capacities below 3 MWth), testing/use of emergency diesel generators, and use of natural gas for cooking. With respect to remodeling projects, air emissions sources will be primarily from diesel generators and vehicle engines, as well as dust.
Hazardous substances, such as diesel, are stored in dedicated areas. Tanks containing natural gas and medical gas are inspected and certified as per state/national law and standards. Radioactive substances are not used by the Company.
In order to systematically identify and mitigate impacts and risks associated with resource efficiency and pollution across its operational hospitals, as part of ESAP item #1, Polar will develop an E&S Assessment & Management Procedure in accordance with the requirements of IFC PS, WBG EHS Guidelines for Health Care Facilities (2007) and WBG General EHS Guidelines (2007).
PS4: Community Health, Safety and Security
Community Health and Safety
For remodeling works, as part of ESAP item #7, the Company will update the CCMP, and create a supplementary procedure, to include the minimum community health and safety requirements for construction contractors, consistent with the IFC PS and WBG General EHS Guidelines. This will include a transportation safety plan and segregation of the public from workplace hazards.
Life and Fire Safety
L&FS infrastructure and systems are based on local fire codes, including fire extinguishers, fire detection, fire hose reels, exit signage and emergency lighting. Polar engages third-party L&FS professionals who certify that Company buildings are designed, constructed and operated in a manner compliant with national building and fire codes.
As per ESAP item #8, the Company will commission a qualified L&FS professional to audit the hospital portfolio and develop a corporate L&FS Design Manual (Master Plan), including accessibility requirements. The Design Manual will include the minimum requirements for all hospitals, and potential acquisition targets will be screened against the requirements to determine the works necessary to achieve compliance. On completion of the works, a L&FS professional will certify compliance with the requirements. For operations and maintenance activities across the portfolio, the Design Manual will include the minimum inspection, testing, maintenance and change management requirements.
Safeguarding of Vulnerable Individuals
As required by local regulations, the hospitals have developed specific protocols for attending to vulnerable individuals, including provisions to safeguard their integrity, confidentiality and dignity. The protocols include steps to define vulnerabilities and identify safeguarding needs. As part of ESAP item #1, Polar will develop a corporate Safeguarding Standard including provisions for additional types of vulnerable groups and will train personnel on the updated protocols.
Security
Polar employes security personnel to control access and deter theft of materials. They undergo background checks before being hired, are unarmed. Training is provided on how to interact with patients and their families. To systematically manage security at the corporate level, as part of ESAP item #1, the corporate ESMS will include a corporate security procedure in line with IFC PS4, and security personnel at each hospital will comply with the principles of conduct outlined in the procedure.
